84770 Federal Register / Vol. 88, No. 233 / Wednesday, December 6, 2023 / Proposed Rules 

DEPARTMENT OF THE TREASURY 

Internal Revenue Service 

26 CFR Part 1 

[REG–132422–17] 

RIN 1545–BO07 

Income and Currency Gain or Loss 

With Respect to a Qualified Business 

Unit; Correction 

AGENCY: Internal Revenue Service (IRS), 

Treasury. 

ACTION: Notice of proposed rulemaking; 

correction. 

SUMMARY: This document contains a 

correction to a notice of proposed 

rulemaking that was published in the 

Federal Register on Tuesday, November 

14, 2023. The proposed regulations 

provide guidance relating to the 

determination of taxable income or loss 

and foreign currency gain or loss with 

respect to a qualified business unit. 

DATES: Written or electronic comments 

and requests for a public hearing are 

still being accepted and must be 

received by February 12, 2024. 

ADDRESSES: Commenters are strongly 

encouraged to submit public comments 

electronically via the Federal 

eRulemaking Portal at https://

www.regulations.gov (indicate IRS and 

REG–132422–17) by following the 

online instructions for submitting 

comments. Requests for a public hearing 

must be submitted as prescribed in the 

‘‘Comments and Requests for a Public 

Hearing’’ section. Once submitted to the 

Federal eRulemaking Portal, comments 

cannot be edited or withdrawn. The 

Department of the Treasury and the IRS 

will publish for public availability any 

comments submitted to the IRS’s public 

docket. Send paper submissions to: 

CC:PA:01:PR (REG–132422–17), Room 

5203, Internal Revenue Service, P.O. 

Box 7604, Ben Franklin Station, 

Washington, DC 20044. 

FOR FURTHER INFORMATION CONTACT: 

Concerning the proposed regulations, 

Raphael J. Cohen at (202) 317–6938; 

concerning submissions of comments, 

requests for a public hearing, and access 

to a public hearing, Vivian Hayes at 

(202) 317–6901 (not toll-free numbers) 

or by email to publichearings@irs.gov 

(preferred). 

SUPPLEMENTARY INFORMATION: 

Background 

On November 14, 2023, the Federal 

Register published a notice of proposed 

rulemaking and partial withdrawal of 

notice of proposed rulemaking (REG– 

132422–17) at 88 FR 78134 (the 

proposed regulations). The proposed 

regulations that are the subject of this 

correction are issued under sections 

861, 985 through 989, and 1502 of the 

Internal Revenue Code. 

Need for Correction 

As published, the preamble to the 

proposed regulations contains errors 

that may prove to be misleading. This 

document provides a technical 

correction to the preamble, which 

clarifies the misleading paragraph. 

Correction of Publication 

Accordingly, the publication of the 

proposed regulations (REG–132422–17), 

which was the subject of FR Doc. 2023– 

24649, published on November 14, 

2023, is corrected on page 78156, in the 

third column, by revising the first full 

paragraph to read, ‘‘Taxpayers may rely 

on the proposed regulations (and so 

much of the final regulations as would 

not be modified by the proposed 

regulations) for taxable years ending 

after November 9, 2023, provided the 

taxpayer and each member of its 

consolidated group and section 987 

electing group consistently follow the 

proposed regulations in their entirety 

and in a consistent manner. 

Additionally, for taxable years ending 

after November 9, 2023, and beginning 

on or before December 31, 2024, 

taxpayers may rely on only the 

applicability date provisions in 

proposed §§ 1.861–9(g)(2)(v), 1.985–5(g), 

1.987–14(a), (c), and (d), 1.988–1(i), 

1.988–4(b)(2)(ii), and 1.989(a)–1(b)(4) 

and (d)(4), provided that: (1) the 

taxpayer and each member of its 

consolidated group and section 987 

electing group consistently follow those 

provisions in their entirety and in a 

consistent manner for those taxable 

years; (2) with respect to any 

terminating QBU to which proposed 

§ 1.987–14(a)(2) would apply or 

partnership to which proposed § 1.987– 

14(a)(3) would apply, the taxpayer and 

each member of its consolidated group 

and section 987 electing group 

consistently follow all of the proposed 

regulations (and so much of the final 

regulations as would not be modified by 

the proposed regulations) in their 

entirety and in a consistent manner; and 

(3) to the extent that, under proposed 

§ 1.987–14(c), proposed § 1.987–10 

would be applied in lieu of prior 

§ 1.987–10, the taxpayer and each 

member of its consolidated group and 

section 987 electing group consistently 

follow proposed § 1.987–10 in its 

entirety and in a consistent manner. 

Thus, for example, a calendar year 

taxpayer that has consistently followed 

the method described in the 1991 

proposed regulations could continue to 

follow that method for the 2024 taxable 

year in reliance on proposed § 1.987– 

14(a)(1) (and would not need to follow 

the other parts of the proposed 

regulations, except to the extent 

provided in the prior sentence).’’ 

Oluwafunmilayo A. Taylor, 

Section Chief, Publications and Regulations 

Section, Associate Chief Counsel (Procedure 

and Administration). 

[FR Doc. 2023–26785 Filed 12–5–23; 8:45 am] 

BILLING CODE 4830–01–P 

DEPARTMENT OF THE TREASURY 

Internal Revenue Service 

26 CFR Parts 1, 5, 301, and 602 

[REG–134420–10] 

RIN 1545–BJ87 

Revising Consolidated Return 

Regulations To Reflect Statutory 

Changes, Modernize Language, and 

Enhance Clarity; Correction 

AGENCY: Internal Revenue Service (IRS), 

Treasury. 

ACTION: Notice of proposed rulemaking; 

correction. 

SUMMARY: This document corrects a 

notice of proposed rulemaking (REG– 

134420–10) published in the Federal 

Register on August 7, 2023, modifying 

regulations applicable to affiliated and 

controlled groups of corporations in 

order to reflect statutory changes, 

update language to remove antiquated 

or regressive terminology, and enhance 

clarity. The correction makes parallel 

amendments to similar regulations 

applicable to controlled groups of 

corporations. 

DATES: The comment period for REG– 

134420–10 (88 FR 52057, August 7, 

2023) is reopened, and additional 

written or electronic comments and 

requests for a public hearing must be 

received by February 5, 2024. 

ADDRESSES: Commenters are strongly 

encouraged to submit public comments 

electronically. Submit electronic 

submissions via the Federal 

eRulemaking Portal at https://

www.regulations.gov (indicate IRS and 

REG–134420–10). Once submitted to the 

Federal eRulemaking Portal, comments 

cannot be edited or withdrawn. The 

Department of the Treasury (the 

Treasury Department) and the IRS will 

publish for public availability any 

comment submitted to its public docket. 

Send paper submissions to: 


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Federal Register / Vol. 88, No. 233 / Wednesday, December 6, 2023 / Proposed Rules 84771 

CC:PA:01:PR (REG–134420–10), Room 

5203, Internal Revenue Service, P.O. 

Box 7604, Ben Franklin Station, 

Washington, DC 20044. 

FOR FURTHER INFORMATION CONTACT: 

Concerning the proposed regulations 

under section 52, Kari DiCecco of the 

Office of Associate Chief Counsel 

(Employee Benefits, Exempt 

Organizations, and Employment Taxes) 

at (202) 317–5500; concerning the 

proposed regulations under section 414, 

Jessica Weinberger of the Office of 

Associate Chief Counsel (Employee 

Benefits, Exempt Organizations, and 

Employment Taxes) at (202) 317–4148 

(not toll-free numbers). 

SUPPLEMENTARY INFORMATION: 

Background 

The notice of proposed rulemaking 

(REG–134420–10) that is the subject of 

this correction is under sections 1502, 

1503, 1552, and 1563. The regulations 

under sections 52 and 414 provide rules 

similar to the rules under section 1563. 

An amendment to the regulations under 

section 1563 without parallel 

amendments to the regulations under 

sections 52 and 414 would create 

inconsistencies. This correction would 

make parallel changes to the regulations 

under sections 52 and 414. 

Need for Correction 

As published, REG–134420–10 

created inconsistencies by revising 

§ 1.1563–1 without revising parallel 

language in two additional regulations. 

Correction of Publication 

Accordingly, the publication of the 

proposed regulations (REG–134420–10), 

which was the subject of FR Doc. 2023– 

14098, is corrected as follows: 

1. On page 52062, the second column, 

after the first full paragraph, the 

following language is added: 

‘‘Sections 52(a) and 414(b) provide 

rules for controlled groups of 

corporations that incorporate section 

1563(a), with modifications. Sections 

52(b) and 414(c)(1) authorize regulations 

applying the principles of 52(a) and 

414(b) to trades or businesses under 

common control. The regulations under 

sections 52(b) and 414(c)(1) include 

constructive ownership rules that mirror 

the rules under section 1563. 

Accordingly, the proposed regulations 

would revise §§ 1.52–1(c)(1) and 

1.414(c)–2(b)(1) in the same way as they 

revise § 1.1563–1(a)(2).’’. 

2. In the Proposed Amendments to the 

Regulations, pages 52069 through 

52082, ‘‘Par. 6. through Par. 57.’’ is 

redesignated as ‘‘Par. 8. through Par. 

59.’’ respectively, ‘‘Par. 2. through Par. 

5.’’ is redesignated as ‘‘Par. 3. through 

Par. 6.’’ respectively, and new ‘‘Par. 2. 

and Par. 7.’’ are added in numerical 

order. 

§ 1.52–1 [Amended] 

3. Newly added Par. 2. should read as 

‘‘Par. 2. Section 1.52–1 is amended by 

removing the text ‘‘(directly and with 

the application of § 1.414(c)–4(b)(1), 

relating to options)’’ from paragraph 

(c)(1) wherever it appears and adding 

the text ‘‘(directly and with the 

application of § 1.414(c)–4(b)(1), (2), and 

(3))’’ in its place.’’. 

§ 1.414(c)–2 [Amended] 

4. Newly added Par. 7. should read as 

‘‘Par. 7. Section 1.414(c)–2 is amended 

by removing the text ‘‘(directly and with 

the application of § 1.414(c)–4(b)(1), 

relating to options)’’ from paragraph 

(b)(1) wherever it appears and adding 

the text ‘‘(directly and with the 

application of § 1.414(c)–4(b)(1), (2), and 

(3))’’ in its place.’’. 

Oluwafunmilayo A. Taylor, 

Section Chief, Publications and Regulations 

Section, Associate Chief Counsel, (Procedure 

and Administration). 

[FR Doc. 2023–26601 Filed 12–5–23; 8:45 am] 

BILLING CODE 4830–01–P 

FEDERAL COMMUNICATIONS 

COMMISSION 

47 CFR Part 73 

[MB Docket No. 23–406; RM–11969; DA 23– 

1107; FR ID 188092] 

Television Broadcasting Services 

Greenville, South Carolina 

AGENCY: Federal Communications 

Commission. 

ACTION: Proposed rule. 

SUMMARY: The Video Division, Media 

Bureau (Bureau), has before it a petition 

for rulemaking filed September 27, 

2023, by Carolina Christian 

Broadcasting, Inc. (Petitioner), the 

licensee of WGGS–TV, channel 2, 

Greenville, South Carolina (Station or 

WGGS). The Petitioner requests the 

substitution of channel 29 for channel 2 

at Greenville, South Carolina 

(Greenville) in the Table of TV 

Allotments. 

DATES: Comments must be filed on or 

before January 5, 2024 and reply 

comments on or before January 22, 

2024. 

ADDRESSES: Federal Communications 

Commission, Office of the Secretary, 45 

L Street NE, Washington, DC 20554. In 

addition to filing comments with the 

FCC, interested parties should serve 

counsel for the Petitioner as follows: 

Joseph C. Chautin, III, Esq., Hardy, 

Carey, Chautin & Balkin, LLP, 1080 

West Causeway Approach, Mandeville, 

Louisiana 70471. 

FOR FURTHER INFORMATION CONTACT: 

Joyce Bernstein, Media Bureau, at (202) 

418–1647; or Joyce Bernstein, Media 

Bureau, at Joyce.Bernstein@fcc.gov. 

SUPPLEMENTARY INFORMATION: In support 

of its channel substitution request, the 

Petitioner states that its proposed 

channel substitution would serve the 

public interest by resolving reception 

challenges currently experienced by 

viewers in the WGGS service area, and 

substantially improving access to the 

Station’s programming. According to the 

Petition, the Station regularly receives 

phone calls and email from viewers no 

longer able to receive the Station’s 

signal. The Petitioner notes that the 

Commission has recognized that VHF 

channels have certain characteristics 

that pose challenges for their use in 

providing digital television service, 

including a large variability in the 

performance of indoor antennas 

available to viewers, with most antennas 

performing very poorly on VHF 

channels. The Petitioner proposes to 

operate the Station on channel 29 with 

a 3-node Distributed Transmission 

System (DTS) facility. While an analysis 

using the Commission’s TVStudy 

software indicates that the Station’s 

move to channel 29 would create a 

predicted population loss area of 

946,964 persons, mostly located around 

the edge of the channel 2 noise limited 

contour, almost all of the population 

would remain ‘‘well-served’’ by five or 

more full power or Class A television 

signals. According to the Petitioner, 

only 417 persons predicted to live in the 

loss area would no longer be considered 

‘‘well-served,’’ and none of those 

persons would receive over-the-air 

television service from fewer than four 

stations. All viewers within the 

Station’s community of license will 

continue to be served by the Station. 

We believe that the Petitioner’s 

channel substitution proposal for WGGS 

warrants consideration. Channel 29 can 

be substituted for channel 2 at 

Greenville, South Carolina, as proposed, 

in compliance with the principal 

community coverage requirements of 

section 73.625(a) of the Commission’s 

Rules (rules), at coordinates 34–56′– 

26.4′′ N and 82–24′–40.4′′ W. In 

addition, we find that this channel 

change meets the technical 

requirements set forth in sections 73.616 

and 73.623 of the rules. Although the 

proposal would result in a loss of 

service to 946,964 persons, all but 417 


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